Colorado v. Spring

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Colorado v. Spring
Seal of the United States Supreme Court.svg
Argued December 9, 1986
Decided January 27, 1987
Full case nameColorado v. Spring
Citations479 U.S. 564 ( more )
107 S. Ct. 851; 93 L. Ed. 2d 954
Case history
PriorConviction reversed by Colo Ct App., 671 P.2d 965, 966 (1983), and decision affirmed upon further appeal by Colo Sp Ct, 713 P.2d 865 (1985).
Holding
A suspect's awareness of which crime law enforcement is interrogating him about is not relevant in determining the validity of his waiver of Fifth Amendment rights.
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr.  · Byron White
Thurgood Marshall  · Harry Blackmun
Lewis F. Powell Jr.  · John P. Stevens
Sandra Day O'Connor  · Antonin Scalia
Case opinions
MajorityPowell, joined by Rehnquist, White, Blackmun, Stevens, O'Connor, Scalia
DissentMarshall, joined by Brennan
Laws applied
U.S. Const. amend. V

Colorado v. Spring, 479 U.S. 564 (1987), was a United States Supreme Court case in which the Court held that a suspect's awareness of the crimes about which he may be questioned is not relevant to his waiver of his Fifth Amendment rights.

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution. Executive acts can be struck down by the Court for violating either the Constitution or federal law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.

Fifth Amendment to the United States Constitution Amendment guaranteeing rights related to trials and due process

The Fifth Amendment to the United States Constitution addresses criminal procedure and other aspects of the Constitution. It was ratified in 1791 as part of the Bill of Rights. The Fifth Amendment applies to every level of the government, including the federal, state, and local levels, as well as any corporation, private enterprise, group, or individual, or any foreign government in regards to a US citizen or resident of the US. The Supreme Court furthered the protections of this amendment through the Due Process Clause of the Fourteenth Amendment.

Contents

Background

While on vacation in Colorado, a man named John Leroy Spring purportedly murdered one Donald Walker in the month of February 1979. There was supposedly an anonymous accomplice who assisted Spring, but no such person was ever apprehended in the investigation of Walker's death. An informant, whose identity was concealed, tipped off agents in the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) as to Spring's alleged involvement in the illegal interstate transportation of ill-gotten firearms. The agents also learned that John Spring talked with an unknown party about the Walker homicide and the role he played in it. [1]

Bureau of Alcohol, Tobacco, Firearms and Explosives federal law enforcement organization of the United States

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is a federal law enforcement organization within the United States Department of Justice. Its responsibilities include the investigation and prevention of federal offenses involving the unlawful use, manufacture, and possession of firearms and explosives; acts of arson and bombings; and illegal trafficking and tax evasion of alcohol and tobacco products. The ATF also regulates via licensing the sale, possession, and transportation of firearms, ammunition, and explosives in interstate commerce. Many of the ATF's activities are carried out in conjunction with task forces made up of state and local law enforcement officers, such as Project Safe Neighborhoods. The ATF operates a unique fire research laboratory in Beltsville, Maryland, where full-scale mock-ups of criminal arson can be reconstructed. The agency is led by Thomas E. Brandon, Acting Director, and Ronald B. Turk, Acting Deputy Director. The ATF has 4,770 employees, and an annual budget of $1.15 billion (2012).

Working off the information provided by the informant, ATF agents planned out a sting operation to arrest Spring on the 30th of March. Their goal came to fruition, as Spring was successfully caught and arrested in Kansas City, Missouri for the crime of the illegal distribution of stolen firearms. They hoped this arrest would provide a launching pad from which to judge him as a suspect in the investigation of the Walker homicide. [1]

Kansas City, Missouri City in western Missouri

Kansas City is the largest city in the U.S. state of Missouri. According to the U.S. Census Bureau, the city had an estimated population of 491,918 in 2018, making it the 38th most-populous city in the United States. It is the central city of the Kansas City metropolitan area, which straddles the Kansas–Missouri state line. Kansas City was founded in the 1830s as a Missouri River port at its confluence with the Kansas River coming in from the west. On June 1, 1850 the town of Kansas was incorporated; shortly after came the establishment of the Kansas Territory. Confusion between the two ensued and the name Kansas City was assigned to distinguish them soon after.

As required by Miranda v. Arizona , Spring was advised of his fifth amendment rights to protection against self-incrimination, an attorney, and silence when interrogated. Spring was actually reminded twice of his rights: first on the scene of the arrest, then again back at the ATF office in Kansas City. However, Spring opted to waive them through written signature. He then voluntarily made a statement and answered questions regarding the ongoing investigation surrounding his involvement in illegal interstate firearms trafficking. [1]

Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the United States Supreme Court. In a 5–4 majority, the Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant was informed of the right to consult with an attorney before and during questioning and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights, but voluntarily waived them.

The ATF agents began the interrogation by asking Spring to elaborate on the firearms transactions that directly led to his arrest, so as not to give away that they planned on eventually questioning about the death of Walker. From there, the agents progressed to the topic of whether or not he had a prior a criminal record. When Spring admitted he shot his aunt at age ten, the agents saw an opportunity. Given Spring had just confessed to shooting someone as close to him as a family member, they questioned whether or not there were other victims. In response, Spring lowered his head and simply uttered the phrase, “I shot another guy once,” [1] without specifically naming or describing the man who he fired upon. The agents pressed further, first asking if he ever visited the state of Colorado in the past, and if the man he claimed to have shot was named Donald Walker. They also questioned if he used a snowbank to hide Walker's corpse, in the case that he did murder the man. Spring responded to both questions with a “no,” and the interview ended at this point. [1]

Nearly two months later, on May 26, 1979, Spring, after having once again waived his Miranda rights through written signature, verbally confessed to the Colorado murder to Colorado law enforcement officers. He then signed a formal statement which bound him to this confession, a confession that would ultimately seal his fate for better or worse. [2]

Trial

When charged with first-degree murder in a Colorado state court, however, Spring and his attorney did not sit idly by. Instead, they moved quickly to nullify the statements made by Spring on May 26 and March 30; the basis of their argument was that the interrogating agents violated his due process rights as decreed by Miranda v. Arizona. Spring and his defending attorney emphasized that, as he was not notified prior to interrogation that he would be questioned about the killing of Donald Walker, the ATF agents pushed him to incriminate himself. [2]

The trial court insisted that this statement be deemed inadmissible not because of the failure by the ATF agents to notify Spring of the focus of the interrogation, but because his statement that he “shot another guy once” was irrelevant, and that the context of the discussion did not point to his aforementioned confession being about his participation in the Walker homicide. However, the court held that the May 26th statement, as it was made freely, voluntarily, and intelligently, should be admitted as evidence, thus convicting Spring of the first-degree murder of Donald Walker. [2]

This holding was reversed by the Colorado Court of Appeals, who sided with the argument proposed by Spring's legal team that the failure on part of the ATF agents to inform Spring of the topic of questioning prior to the interrogation should invalidate the March 30th statement. [2] The court also argued that the State of Colorado failed to substantially prove that the May 26th statement was not the illegal “fruit” of the March 30th statement; this doctrine of “fruit of the poisonous tree” holds that if any evidence is collected through illegal means, like entering a house without a (proper) search warrant, then such evidence must not be admitted into trial. This holds true even for an interrogation; if tactics used in an interrogation are illegal, or if the interrogation itself is illegally performed, then it, along with any physical evidence it produces, may be excluded from trial. [3] The Colorado Supreme Court affirmed the holding made by the Court of Appeals, once again saying the murder confession made on May 26 was the illegal “fruit” of the March 30th statement. [2]

The Supreme Court of the United States, in the Spring decision, reversed the rulings of both the Colorado Supreme Court and the Colorado Court of Appeals. By a vote of seven to two, the Supreme Court held that the interrogating officers’ failure to notify the suspect that they would question him about the Walker murder did not impact, and thus invalidate, his waiver of his Miranda rights. [4] Delivering the majority opinion, Associate Justice Lewis F. Powell, Jr. stated that the Court's only focus of inquiry was the March 30th statement, as it was the illegality of this statement that supposedly marred the May 26th statement. [5]

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References

  1. 1 2 3 4 5 Colorado v. Spring, 479 U.S. 564 (1987).
  2. 1 2 3 4 5 "FindLaw | Cases and Codes." FindLaw | Cases and Codes. Web. 27 Oct. 2014. <http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=479&invol=564>
  3. "Fruit of the Poisonous Tree." LII / Legal Information Institute. Cornell Law, n.d. Web. 10 Dec. 2014. <https://www.law.cornell.edu/wex/fruit_of_the_poisonous_tree>
  4. "Validity of Waiver." LexisNexis Litigation Essentials. LexisNexis, n.d. Web. 11 Dec. 2014. <https://litigation-essentials.lexisnexis.com/webcd/app?action=DocumentDisplay&crawlid=1&srctype=smi&srcid=3B15&doctype=cite&docid=78+J.+Crim.+L.+%26+Criminology+828&key=33dbd2229300e98b276378656a57a6f0>
  5. Spitzer, Gregory E. "Fifth Amendment--Validity of Waiver: A Suspect Need Not Know the Subjects of Interrogation." Journal of Criminal and Criminology. N.p., n.d. Web. 29 Oct. 2014. <http://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=6572&context=jclc>